80 Contacts in 232 Days: Triable Issue on Harassment

[David A. Szwak]

First North American Nat. Bank v. Superior Court, Not Reported in Cal.Rptr.3d, 2005 WestLaw 67123 [Cal. App. 2 Dist. 2005] [Bank placed 35 automated and 34 other types of phone calls to plaintiffs. Also during this time period, Bank sent plaintiffs 11 collection letters. Thus, over a period of approximately 232 days, Bank communicated with plaintiffs a total of 80 times. That means that Bank contacted plaintiffs every third day during this time period. Triable issue as to whether Bank harassed him].